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D17017 1 (2017-07-25)

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cO                   U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548



July 25, 2017


Mr. Matthew Waldron
Technical Director
International Auditing and Assurance Standards Board
529 Fifth Avenue
New York, NY 10017

GAO's Response to the International Auditing and Assurance Standards Board's April
2017 Exposure Draft, Proposed International Standard on Auditing 540 (Revised),
Auditing Accounting Estimates and Related Disclosures

Dear Mr. Waldron:

This letter provides GAO's response to the exposure draft, Proposed International Standard on
Auditing (ISA) 540 (Revised), Auditing Accounting Estimates and Related Disclosures (ED-540).
GAO promulgates generally accepted government auditing standards, which provide
professional standards for auditors of government entities in the United States.

We support the International Auditing and Assurance Standards Board's (IAASB) efforts to
update the standards for auditing accounting estimates. However, we believe that the proposed
standard could benefit from linking the audit procedures in paragraph 15(a) to the audit
evidence required to be obtained in paragraphs 17 through 20. We believe that this approach
will increase the clarity of the standard and will make it easier for auditors to effectively apply.
Further, we suggest that the IAASB consider grouping the guidance in paragraphs 17 through
20 by procedures that evaluate evidence related to methods, data, and assumptions. We have
found this approach to be useful in our audits of complex estimates in the federal government
and believe that it may be easier to apply than the approach described in the proposed
standard, which is organized by the factors complexity, judgment, and estimation uncertainty.
Our responses to IAASB's specific questions follow. We believe that our suggestions will

enhance the consistency of the standard with those promulgated by other standard setters.

Specific Comments

Overall Questions

    1) Has ED-540 been appropriately updated to deal with evolving financial reporting
       frameworks as they relate to accounting estimates?

       We support the IAASB's efforts to update ED-540 to address evolving financial reporting
       frameworks as they relate to accounting estimates. As indicated above, we agree with
       the requirements related to obtaining sufficient appropriate audit evidence in paragraphs
       17 through 20. However, we believe that these requirements should be linked to the
       audit procedures in paragraph 15(a).


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